ML19309E776
| ML19309E776 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/17/1980 |
| From: | Andognini G BOSTON EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8004240357 | |
| Download: ML19309E776 (4) | |
Text
{{#Wiki_filter:% b BOSTON EDISON COMPANY acNama6 orriese eco sayLaToM eT=Ec? oceTON. MaseAcNuesTTe o2199 G. CamL AmoceNINS suptmINTENDENT NUCLEAN OPERATIONe DSpamTedENT April 17, 1980 BECo. Ltr. #80-73 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C. 20555 License No. DPR-35 Docket No. 50-293 Notification of a Claim
Dear Mr. Denton:
Pursuant to 10 CFR 140.6 this letter serves as notification that a claim has been filed against Boston Edison Company arising out of or in connection with its operation of Pilgrim Nuclear Power Station, Unit #1. A copy of the sum-mons and complaint are attached for your information. Should there be any questions concerning this notification, please contact us. Very truly yours, 1, be W 60 e O '/ \\ \\ t i 8004240 l
l I l J COMMONWEALTH OF MASSACHUSE*ITS SUPERIOR COURT DEPARTMENT OF THE ekYhfOUTH, ss. TRIAL COURT OF THE COMMONWEAIJil O CIVIL ACTION NO. EDSON BROOKS and ANNA.. BROOKS..., Plaintiff (s) 1 l vs. I BOSTON EDISON... COMPANY.. ., Defendant (s) I SUMMONS i Et. To the above. named defendant h You are hereby summoned and. require [to. serve upon.. Bernard... Cohen.. plaintiff's attorney, whose address is 28.8...N..Baini.St...Br.o.ckton,...Masan answer to the j 5 r? complaint which is herewith served upon you, within 26 days after service of this summons upon you, exclusinof ths day of service. If you fail tc, do so, fudgment by default will be taken against you for ..[ the relief demanded in the mmplaint. You are also required to file your answer to the complaint in the office of the Clerk of this court at Plymouth either before service upon plaintiff attorney or within a 5 ,,y-reasonable time thereafter. 54 Unless otherwise provided by Rule 13(a), your answer must state as.a counterclaim any claim which E., you may have against the plaintiff which arises out of the transaction or occurrence that is the subject z matterof theplaintiff claim or you will thereafter be barred from making such claim in any other action. ? - 1 Witness, J UlF. P. LYNCH. Jr. Esquire, at Plymouth. the. .1.0 t-h... day of AP.Iil , in the year of our lord one thousand nine hundred and swNettp. 80 t .i ~ AT E CdPY, AT E T f >-t1 f _ q fpt i. DEPUTY SHERIFF NOTES CLERK. I I
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- 1. ' Itis summons is issued pursuant to Rule 4 of the Massachusetts Rules of Civil Procedure.
2. When mere than one defendant is involved, the names of all defendants'should appear in the caption. If a separate summons is used for each defendant, each should'be addressed to the particular defendant. 3. To plaintiff's attorney: please circle type of action involved - Tort - Motor Vehicle Tort - Contract - Equitable Relief -- Othe. PROOF OF SERVICE OF PROCESS I hereby certify and return that on. 197 . I served a mpy of the within surrmons, together with a copy of the complaint in this action, upon the within. named ~ defendant , in the following manner (See Mass. R. Civ. P. 4 (d) (15): c - n. ~ ' ;, k Dated: ,197 ~;. N.,,B._,TO_ PROCESS SERVER:- PLEASE PLACE DATE YOU MAKE SERVICE ON DEFENDANT IN TIIIS BOX ON THE ORIGINAL AND ON COPY SERVED ON DEFENDANT. ~ l $/ N ^*~ a
a - --= COMMONWEALTH OF MAS.'jACHUSETTS o ~,s PLYMOUTH, SS: SUPERIOR COURf 4 NO. EDSON BROOKS and ANNA ) BROOKS ) ) PLAINTIFFS ) ) VS ) COMPLAINT ) BOSTON EDISON COMPANY ) ) DEFENDANT ) l t l I 1 COUNT I Edson Brooks v. Boston Edison Company ~ l 1. The plaintiff Edson Brooks in a resident of Whitman, i l County of Plymouth, Massachusetts. l l 2. Boston Edison is a Corporation duly organized by law in doing business in Plymouth, County of Plymouth, Massachusetts. 3. On various dates in,1977 the plaintiff Edson Brooks was lawfully on the premises of the defemdut at the site of l the Pilgram Nuclear Power Plant in Plymouth, Massachusetts while ,) i in the course of his employment as a Mill Wright. fl i', i, 4. While he was on said premises and at all times in.the I exercise of due care he was subjected to unusual and excesive amounts of radiation due to the negligence of the plaintiff in i t i ' { failing to provide him with proper protective clothing and i i i failure to adequately maintain its premises and failure to adequate:! warn the plaintiff of the damages he was being subjected to. g 5. Due to this exposure to radiation the plaintiff contracted l I cancer of the throat, was forced to suffer medical bills, loss of l BERN ARD CCHEN, INC. i ! noe wsern main eresst f C20 a rON. Mass. 4 ' 'u..y -m v -ni - Q Ab '.r w. Mwz u;;s ~, :-{=LW22MMl&kQ?NO$5 --
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L u.:_ r-1 , a earning capacity, pain and permanent injury, WHEREFOR 3, the plaintiff claims damages against the defendant in the amount of One Million ($1,000.000.00) do"llars together with interest and costs. I i COUNT II Anna Brooks v. Boston Edison Company i I 1. The plaintiff, Anna Brooks, for this cause of action ii repeats and reavers the allegations of paragraphs 1 through 5 of Count I, as if expressly rewritten aid set forth herein. ,i i 2. The plaintiff, Anna Brooks, is the wife of Edson Brooks, I i and states as the direct and proximate result of the negligence of the defendant in causing her husband's injuries, she has been l and will be deprived of full society, services and consortiun of her husband. l 1 WHEREFORE, the plaintifT, Anna Brooks, demands judaree against the defendant in tw mim of $250,000. 00 dollars tacether with interest and costs. i PLAINTIFFS CLAIMS A TRIAL BY JURY. s 4 l The plaintif,fs, l By their attorneys, LAW OFFICES OF BERNARD COHEN, INC. i i By MTIA_ _ [MC l i Ternard Cohen Dated: 4/9/80 l i l l law orrects or BERNARD COHEN. INC. 1 .noex,o.. un... N -m
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